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Fiona Martin

This chapter examines the tax treatment of charities in Australia, New Zealand, England, the United States and Hong Kong. It demonstrates that across these jurisdictions there are substantial differences of approach to important policy questions, for example, relating to the tax treatment of the unrelated business income of charities. Similarly, deductions for charitable donors are handled differently across the world. The chapter emphasizes the diversity of regulatory structures and frameworks across the jurisdictions under review.